3F0214-07, Response to Request for Additional Information Regarding Changes to the Administrative Controls Section of the Technical Specifications
| ML14064A343 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/26/2014 |
| From: | Elnitsky J Duke Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 3F0214-07 | |
| Download: ML14064A343 (5) | |
Text
UKE Crystal River Nuclear Plant DUKER 15760 W. Power Line Street
- ENERGY, Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.90 February 26, 2014 3F0214-07 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Response to Request for Additional Information Regarding Changes to the Administrative Controls Section of the Technical Specifications
References:
- 1. Crystal River Unit 3 to NRC letter, "License Amendment Request #313, Revision 0, Revision to Improved Technical Specifications Administrative Controls for Permanently Defueled Conditions," dated April 25, 2013 (ADAMS Accession No. ML13128A286)
- 2. NRC to CR-3 Electronic Mail, "Request for Additional Information Regarding Changes to the Administrative Controls Section of the Technical Specifications," dated February 12, 2014
Dear Sir:
In Reference 1 Duke Energy Florida, Inc. (DEF), requested changes to the Administrative Controls Section of the Crystal River Unit 3 (CR-3) Technical Specifications (TS). The request included a change to Section 5.8, "High Radiation Area."
In Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information on the controls for high radiation areas contained in Section 5.8 in regards to the implementation of 10 CFR 20.1602, "Control of access to very high radiation areas." to this letter contains the NRC request for additional information and the CR-3 response. Attachment 2 contains a new regulatory commitment to provide a change to TS Section 5.8 in a future submittal.
If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Manager, Nuclear Regulatory Affairs, at (352) 563-4796.
I declare under penalty of perjury that the foregoing is true and correct. Executed on February 26, 2014.
itsent___
ject aonagement and Construction JE/scp Attachments:
- 1.
Response to Request for Additional Information
- 2.
NRR Project Manager A-0(
Regional Administrator, Region I
ý, 4-P State Contact
DUKE ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGES TO THE ADMINISTRATIVE CONTROLS SECTION OF THE TECHNICAL SPECIFICATIONS ATTACHMENT I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
U. S. Nuclear Regulatory Commission 3F0214-07 Page 1 of 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Request for Additional Information Title 10 of the Code of Federal Regulations (10 CFR), Section 20.1601, requires licensees to control access to High Radiation Areas (HRA, or areas > 100 millirem (mrem)/hour (hr)). This regulation is fairly prescriptive but does allow licensees (per 10 CFR 20.1601(c)) to request alternate controls. All power reactor licensees have adopted alternate controls that relieve the requirement to lock HRAs, unless they have dose rates > 1000 mrem/hr. In other words, these licensees do not need to lock HRAs from 100 mrem/hr to 1000 mrem/hr if they implement the compensatory requirements of the TSs.
In the 1990 revision to 10 CFR 20, the NRC defined a Very High Radiation Area (VHRA) as an area with dose rates > 500 rad/hr and added 10 CFR 20.1602 to require more stringent controls in addition to those required by 10 CFR 20.1601. The NRC subsequently revised the Standard Technical Specifications to clarify that the alternate controls approved in the TS did not apply to VHRAs.
Sections 5.8.2 and 5.8.3 of the proposed CR3 TS state that the alternate controls specified in each apply to "areas with radiation levels > 1000 mrem/hr at 30 cm." A plain reading of these would include areas greater than 500 rad/hr (e.g., a Very High Radiation Area), which is not consistent with Part 20.
Please clarify how the proposed wording meets the requirements of 10 CFR 20.1602, or propose wording that complies with the requirements of 10 CFR 20.1602.
Crystal River Unit 3 Response to Request for Additional Information In a telephone conversation between the NRC Project Manager for CR-3 and the CR-3 Manager, Nuclear Regulatory Affairs on February 20, 2014, agreement was reached on a method to change TS 5.8.2 and 5.8.3 which would address the NRC concern that the CR-3 ITS, Sections 5.8.2 and 5.8.3, are not consistent with 10 CFR Part 20.
CR-3 converted to the Improved Technical Specifications (ITS) in 1993, based on Revision 0 to the ITS NUREG for Babcock and Wilcox reactors (NUREG 1430). Revision 0 did not include the revision to Part 20 as part of these sections, but later revisions of the ITS NUREG did incorporate this change. A subsequent revision to Section 5.8.2 did not recognize the need to revise these sections as the result of the regulation change.
During the telephone conversation, it was further agreed that the NRC would complete its review and approval of License Amendment Request (LAR) #313, Revision 1, as it is currently proposed, as the affected wording was not identified as being within the scope of changes in the LAR. The wording to be added to these sections will be similar to the existing wording in the corresponding section of the Improved Technical Specification (NUREG 1430, Revision 4). In, CR-3 is providing a regulatory commitment to submit the agreed upon change to TS 5.8.2 and 5.8.3 in a revision to LAR #316, Revision 0, "Revise and Remove License Conditions and Revision to Improved Technical Specifications to Establish Permanently Defueled Technical Specifications," (ADAMS Accession No. ML13316C083) by August 15, 2014.
DUKE ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGES TO THE ADMINISTRATIVE CONTROLS SECTION OF THE TECHNICAL SPECIFICATIONS ATTACHMENT 2 REGULATORY COMMITMENT
U. S. Nuclear Regulatory Commission 3F0214-07 Page 1 of 1 REGULATORY COMMITMENT The following table identifies those actions committed to by Duke Energy Florida, Inc. in this document. Other statements in this correspondence are provided for information purposes and are not considered to be regulatory commitments. Please notify the Crystal River Unit 3 (CR-3)
Manager, Nuclear Regulatory Affairs of any questions regarding this document or any associated regulatory commitments.
Regulatory Commitment Due Date/Event CR-3 will submit a revision to License August 15, 2014 Amendment Request #316, Revision 0, "Revise and Remove License Conditions and Revision to Improved Technical Specifications to Establish Permanently Defueled Technical Specifications," to revise Technical Specifications 5.8.2 and 5.8.3 proposing wording that complies with the requirements of 10 CFR 20.1602.